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Guide · Marketplace sellers

Section 22f German VAT Act: what marketplace sellers outside the EU need

By PortoDoc · Updated · 10 min read

§ 22f UStG concerns you twice if you sell on Amazon, eBay, Etsy or another marketplace into Germany: the marketplace keeps records on you. Based outside the EU and the EEA, you also name an authorised recipient in Germany for marketplace sales, with your application for VAT registration.

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Does this apply to you?

  1. 01Do you sell goods through an online marketplace (elektronische Schnittstelle, electronic interface)?

    Yes
    Read on: § 22f and § 25e UStG are about sales through marketplaces.
    No
    This guide is not for you. For VAT in Germany in general, see our VAT guide.

  2. 02Do your goods start or end their journey in Germany, for example shipped from a warehouse in Germany or delivered to customers here?

    Yes
    The marketplace keeps § 22f records on these sales (§ 22f (1) sentence 1 UStG).
    No
    The records under § 22f (1) UStG only cover deliveries that start or end in Germany.

  3. 03Is your business based outside the EU and the EEA (no residence, habitual abode, seat or management in Germany, another EU country or an EEA country)?

    Yes
    If your business is based outside the EU and the EEA and intends to make sales through a marketplace that are taxable in Germany, you name an authorised recipient in Germany with your application for VAT registration (UStAE 22f.2).
    No
    The authorised-recipient duty of § 22f does not apply to you. The marketplace still records your VAT details.

Yes to all three? Then the steps below apply to you.

What does the marketplace record?

The marketplace operator (Betreiber) must record these details for deliveries that start or end in Germany (§ 22f (1) sentence 1 UStG), unless it is treated as the seller itself (§ 3 (3a) UStG):

  • About you: full name and address, e-mail address or website (nos. 1–2).
  • Your tax numbers: your German VAT identification number (Umsatzsteuer-Identifikationsnummer, USt-IdNr.) from the Federal Central Tax Office (Bundeszentralamt für Steuern, BZSt); your German tax number (Steuernummer), if known (nos. 3–4).
  • Your bank details or virtual account number, if known (no. 5).
  • Each sale: where shipping starts and ends, date and amount, a description of the goods, and the order or transaction number, if known (nos. 6–9).

Kept for ten years: the marketplace keeps these records for ten years and sends them to the tax office electronically on request (§ 22f (4) UStG). If you registered on the marketplace as a private seller, it records your name, address, the sale details and your date of birth (§ 22f (2) UStG).

Does the old certificate still count?

The old certificate no longer counts: until 30 June 2021, marketplaces relied on a paper from the tax office confirming your registration (Bescheinigung über die steuerliche Erfassung, applied for on form USt 1 TJ). For sales after 30 June 2021, it is no longer accepted (UStAE 22f.1 (2) sentence 4). More in letter types A–Z.

Your German VAT ID counts: since 1 July 2021, the marketplace records it as proof of registration (UStAE 22f.1 (2) sentence 2). With approval from its tax office, it can have German VAT IDs confirmed by the BZSt (UStAE 18e.3).

What happens if you are not registered?

  • The marketplace is liable for VAT you do not pay on sales it supports (§ 25e (1) UStG). This does not apply where the marketplace itself is treated as the seller for VAT (§ 3 (3a) UStG).
  • No liability with a valid German VAT ID at the time of the sale, unless the marketplace knew, or should have known, that you are not meeting your tax obligations, or not in full (§ 25e (2) UStG).
  • Request from the marketplace: if it learns of a breach, it asks you to fix it within at most two months. If you do not, it only avoids liability by blocking all your seller accounts (UStAE 25e.2 (3)).
  • Notice from your tax office: if you do not meet your tax obligations, or not to a significant extent, and other measures do not promise immediate success, your tax office may inform the marketplace (§ 25e (4) UStG). Not naming an authorised recipient under § 22f (1) sentence 2 UStG is one of the breaches the tax authorities list (UStAE 25e.3 (1)).

What should you do?

  1. 01Find your tax office. It depends on the country where your business is based (§ 1 UStZustV): for example Bonn-Innenstadt for the USA, Hannover-Nord for the United Kingdom, Dortmund-Unna for Türkiye. Countries not listed, such as China, belong to Berlin International. The Finanzamt finder shows yours.
  2. 02Apply for VAT registration with the questionnaire for businesses based abroad. Our guide to the registration form shows each section.
  3. 03Name an authorised recipient (_Empfangsbevollmächtigter_) in the same application, if your business is based outside the EU and the EEA and sells through a marketplace (§ 22f (1) sentence 2 UStG). It does not need to be authorised to give tax advice (UStAE 22f.2).
  4. 04Enter your German VAT ID in your seller account once you have it. The marketplace records it (§ 22f (1) sentence 1 no. 3 UStG).
  5. 05Read every letter from the tax office. It writes in German, and its letters set deadlines.

What differs for EU and non-EU sellers?

§ 22f and § 25e UStG for sellers in another EU country and outside the EU and the EEA
TopicBased in another EU countryBased outside the EU and the EEA
Marketplace recordsYes, for deliveries that start or end in GermanyYes, for deliveries that start or end in Germany
Proof the marketplace recordsYour German VAT ID. Exceptions (UStAE 25e.2 (1)): only distance sales into Germany below the threshold (§ 3c (4) UStG): your VAT ID from another EU country or, without one, a declaration from you; only distance sales declared through the One-Stop-Shop (OSS): the VAT ID of the EU country where you use the OSSYour German VAT ID; in a few cases without a German registration duty, a declaration from you (UStAE 25e.2 (1))
Authorised recipient in GermanyNot required by § 22f; voluntaryRequired with the application for VAT registration for marketplace sellers outside the EU and the EEA (§ 22f (1) sentence 2 UStG)
If the tax office asks for one (§ 123 AO)Does not applyApplies to every business outside the EU and the EEA

Which mistakes are common?

  • Waiting for the tax office to ask. For marketplace sellers outside the EU and the EEA, the authorised recipient belongs in the application itself. If the conditions only arise later, name one without being asked (UStAE 22f.2).
  • Relying on the old certificate. It is not accepted for sales after 30 June 2021 (UStAE 22f.1 (2)).
  • Registering as a private seller while trading as a business. Sales of 22,000 euros or more on one marketplace in a calendar year are a clear sign that a private registration is wrong (UStAE 25e.2 (4)).
  • Mixing up tax number and VAT ID. The marketplace needs the VAT ID issued by the BZSt (§ 22f (1) sentence 1 no. 3 UStG); the tax number from your tax office is a different number.

Next step

Read on: what an authorised recipient does and how you name one: Authorised recipient in Germany. VAT registration as a whole: VAT in Germany for non-EU sellers.

Common questions

Is the authorised recipient required by Amazon or by German law?

By German law. Marketplace sellers based outside the EU and the EEA name one with their application for VAT registration (§ 22f (1) sentence 2 UStG). The marketplace records your German VAT ID (§ 22f (1) sentence 1 no. 3 UStG).

Is an authorised recipient the same as a tax adviser?

No. An authorised recipient receives the tax office's letters for you. It does not need to be authorised to give tax advice (UStAE 22f.2), and it does not file your returns.

My company is in the EU. Do I need an authorised recipient to sell on Amazon.de?

Not under § 22f UStG: that duty only covers businesses outside the EU and the EEA. § 123 AO also only applies outside the EU and the EEA. You can name one voluntarily.

The marketplace asks for my certificate of registration. Do I still need one?

No. That certificate (applied for on form USt 1 TJ) is not accepted for sales after 30 June 2021. Since 1 July 2021, the marketplace records your German VAT ID instead (UStAE 22f.1 (2)).

Why was my seller account blocked over German VAT?

The marketplace can be liable for VAT you have not paid (§ 25e UStG). It avoids this by blocking all your seller accounts if a breach is not fixed in time or after a notice from your tax office (UStAE 25e.2 (3), 25e.3). Your tax office or a tax adviser can tell you what is missing.

Which tax office do I register with?

It depends on the country where your business is based (§ 1 UStZustV): for example Bonn-Innenstadt for the USA, Hannover-Nord for the United Kingdom, Dortmund-Unna for Türkiye. Countries not listed, such as China, belong to Finanzamt Berlin International.

Can PortoDoc be my authorised recipient?

Yes: you sign our power of attorney and name Postuvio UG (haftungsbeschränkt) to the tax office yourself. We scan your letters, and you get a notification. We give no tax advice and do not file returns.

Next step

GUIDES · 7 MIN READ

German VAT registration form for non-resident businesses: how to fill in the authorised recipient section →

Field by field through the authorised recipient section of the German VAT registration form: what to enter, typical mistakes and an example.

Your authorised recipient in Germany.

We receive your tax office letters in Ahrensburg near Hamburg, scan them and send you a notification. Every plan includes an English AI translation; depending on the plan, you also get an AI summary: an aid, not tax advice; the original letter counts. Starter costs €19.95 a month.

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Sources and legal basis

Last checked on · How we check our information

This guide explains the rules in general terms. It is not tax advice. For your individual situation, ask a tax adviser.